Act No. 385/2025 Coll. — what it actually says about mandatory e-invoicing

What the act changes

The amendment requires VAT payers to issue and receive invoices for domestic supplies of goods and services in a prescribed electronic format. Everyone to whom a VAT payer is obliged to issue an invoice must be able to receive such an invoice. From 2027, electronic invoicing therefore becomes the default way businesses invoice each other in Slovakia.

What counts as an electronic invoice under the act

An electronic invoice is an invoice issued, sent and received in a structured electronic XML format that complies with the European standard EN 16931 in the UBL syntax — a format accounting software can process automatically. An ordinary PDF or a scanned invoice does not meet this definition: those are image documents for a human reader, not structured data for software.

What obligations it creates

• From 1 January 2027, a domestic VAT payer (registered under Section 4, 4b or 4c) must issue an electronic invoice whenever it supplies goods or services with a place of supply in Slovakia to a taxable person or to a non-taxable legal entity — or whenever it receives a payment before such a supply.
• The electronic invoice is delivered through the delivery service under Section 76a (a certified provider); with the recipient's consent it may also be delivered by other means.
• Every legal entity and every business that is a taxable person must be able to receive electronic invoices — including sole traders, the liberal professions and non-VAT payers.
• The data from an issued invoice is reported to the Financial Administration when the invoice is issued; the data from a received invoice within 5 days. If you use a certified provider, it files those reports for you automatically.
• The deadline for issuing an invoice remains 15 days from the supply (or from receipt of payment) — the amendment does not change it.

The summary electronic invoice

The act deals separately with the summary electronic invoice (Section 85o(7)): a VAT payer may issue one for several separate supplies of goods or services made over a period of no more than one calendar month. The summary invoice under Section 75 (covering a longer period) can no longer be used for domestic electronic invoices. Under lease agreements with an agreed payment schedule, an electronic invoice is issued for each recurring lease service.

Exemptions — when an e-invoice must not be issued

Under Section 85o(2), a VAT payer must not issue an electronic invoice where the recipient of the supply is the Slovak Information Service or Military Intelligence, or where the supply involves classified information. Paper invoices are used in those cases. The act recognises no other central list of exemptions — every VAT payer assesses classified supplies for itself.

For now the obligation does not extend to consumer invoices (B2C) — e-invoicing covers business-to-business (B2B) and business-to-government (B2G) transactions.

Penalties

A VAT payer that fails to report invoice data, reports it incorrectly or reports it late faces a fine of up to €10,000. For a repeated breach the fine can reach €100,000. No fine is imposed for an obvious error that the VAT payer corrects immediately, nor where the contracted certified provider demonstrably failed and the data was reported without delay once the fault had been fixed.

How you meet the obligation in practice

In practice you need invoicing software or a certified provider's service that issues the invoice as XML compliant with EN 16931, delivers it over the Peppol network and reports the data to the Financial Administration automatically. eFaktúra is a certified e-invoicing provider (ID EFSK000028) with its own production Peppol Access Point — you can issue and receive e-invoices today, free of charge throughout the transition period.